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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 25

Avoidance of Double Taxation

(1) Double Taxation shall be avoided if:

  • (a) a resident in a Contracting State owns capital or derives income from the other Contracting State, in accordance with the provision of this Convention, he/she may be taxed in that other Contracting State. This income or capital shall not be taxable in the first-mentioned Contracting State without prejudice to the provisions of Articles 2 and 3 of this Convention;
  • (b) a resident in a Contracting State derives income in accordance with the provision of this Convention may be taxed in the other Contracting State, then the first-mentioned Contracting State shall offer a tax discount equal the tax paid to the other Contracting State. In no case shall such discount exceed the tax identified by the other Contracting State calculated prior to the tax discount.

(2) Where the capital owned or income derived by a resident of a Contracting State is exempt from tax in such State, according to the provisions thereof, then the Contracting State may take into account the exempted capital or income while calculating the tax on the remaining part of the capital or income.

Special Provisions